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III48. The City also has a legal duty to act prudently in managing its electric utility • • system in order to protect its customers from unreasonable rates. 49. As described in paragraph 30 above, the City has breached its legal duty to charge only reasonable rates by employing improper rate -making practices that require Non -Resident Customers, including the Plaintiffs, to unfairly subsidize City operations that are not related to the furnishing of electric service to customers. These and other improper rate -making practices by the City have resulted in unreasonable and excessive rates, which the Plaintiffs and other Non -Residential Customers are being forced to pay. 50. As described in paragraph 34 above, the City has breached its duty to prudently operate and manage its electric utility by making a series of ill-advised utility management decisions which have driven the City's cost of power to excessive levels and resulted in the City charging unreasonable electric rates. 51. The Plaintiffs have a clear legal right to pay only those electric rates which are reasonable, just, and equitable, and have been and continue to be harmed by the unreasonable, unjust, and inequitable electric rates charged by the City. 52. The Plaintiffs are being irreparably harmed by the City's continued imposition of rates which are not reasonable, just, and equitable, and have no adequate remedy of law. WHEREFORE, the Plaintiffs request this Court: (1) Declare that the electric utility rates the Plaintiffs are being charged by the City are unreasonable, unjust, and inequitable in violation of the special act creating the City and common law; (2) Enjoin the City from further charging any rates beyond those that are reasonable, just, and equitable; (3) Award Plaintiffs supplemental relief under Section 86.061, Florida Statutes, in the form of a refund of any payment of rates they have made which were in excess of what was reasonable, just, and equitable; and 12